Week 2 of our CTA Update Series – Who is exempt from BOI Reporting

The following is a listing of entities that are not subject to CTA reporting:

i. Securities reporting issuer
ii. Governmental authority
iii. Bank
iv. Credit union
v. Depository institution holding company
vi. Money services business
vii. Broker or dealer in securities
viii. Securities exchange or clearing agency
ix. Other Exchange Act registered entity
x. Investment company or investment adviser
xi. Venture capital fund adviser
xii. Insurance company
xiii. State-licensed insurance producer
xiv. Commodity Exchange Act registered entity
xv. Accounting firm
xvi. Public utility
xvii. Financial market utility
xviii. Pooled investment vehicle
xix. Tax-exempt entity
xx. Entity assisting a tax-exempt entity
xxi. Large operating company
xxii. Subsidiary of certain exempt entities
xxiii. Inactive entity
Today we will concentrate on the Large operating company
A large operating company is an entity that:
o Employs more than 20 full time employees that are employed in the United States. Full-time employee is defined as an employee who is employed an average of at least 30
hours of service per week with an employer.
o Filed a Federal income tax or information return in the United States for the previous
year demonstrating more than $5,000,000 in gross receipts or sales. Gross receipts or
sales from sources outside the United States are excluded from gross income. If the
entity is part of an affiliated group of corporations withing the meaning of 26 U.S.C. 1504
that filed a consolidated return, the amount of receipts/sales (net of returns and
allowances) is the amount on the consolidated return for such group.
o Has an operating presence at a physical office within the United States.


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